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September 2 2020

Position paper on the European Commissinos legislative draft for the review of the Benchmark...

The German Banking Industry Committee welcomes the European Commission’s decision to provide for the possibility to designate a statutory replacement rate for benchmarks, whose cessation would result in a significant disruption in the functioning of...

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June 17 2019

IASB Exposure Draft ED/2019/1 Bechmark Reform

IASB proposes changes to IAS 39 and IFRS 9 due to possible effects of the IBOR reform. GBIC basically agrees with the proposals but advocates also for reliefs concerning retrospective effectiveness testing and dynamic hedging according to IAS 39.

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November 28 2018

Comments on Draft Implementing Standards amending Implementing Regulation with regard to FINREP

We generally welcome the principle of proportionality in the additional reporting obligations for non-performing exposures (NPEs) which is reflected by the separation according to Module 1 and 2. That being said, we believe that it is possible to...

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May 25 2018

EFRAG Discussion Paper Equity instruments – Impairment and Recycling

EFRAG has published a discussion paper where alternative rules for accounting of equity instruments according to IFRS 9 (FV-OCI) are discussed ...

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December 2 2016

EU regulatory framework for benchmarks

The European Securities and Markets Authority ESMA consulted on technical standards under the Benchmarks Regulation. The German Banking Industry Committee contributed to the process and sent its comments to ESMA.

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October 25 2016

EBA guidelines to expected credit lossess

In July 2016, the EBA (European Banking Authority) issued draft guidelines on credit risk management practices and accounting for expected losses.

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October 12 2016

GBIC’s response to the EBA Consultation Paper “EBA-CP-2016-11"

The German Banking Industry Committee (GBIC) welcomes the EBA consultation paper and the opportunity offered to provide feedback on the future draft Regulatory Technical Standards (RTS) on strong customer authentication (SCA) and secure communication...

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September 1 2016

Comments on the European Commission proposal for a directive amending the Fourth Anti-Money...

The German Banking Industry Committee (GBIC) would like to take the reopened debate on creation of an optimal anti-money laundering and counter-terrorist financing (AML/CFT) framework as an opportunity to input its own experience and ideas.

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August 31 2016

Comments on Notice 2016-42 (proposed changes to qualified intermediary agreements)

The new rules in section 5.03(B) of the proposed QI agreement provide that the LOB declaration (which may be used by entities that are not fiscally transparent to document their status together with “alternative” documentary evidence.

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July 29 2016

Comments on the EBA Discussion Paper on innovative uses

The Deutsche Kreditwirtschaft participates on consultation of the European Banking Authority (EBA) for innovative usability of consumer data.

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July 7 2016

Comments on the Basel Committee on Banking Supervision’s consultative document on revisions to the...

The Deutsche Kreditwirtschaft give its opinion to Basels consultation documents for the definition of the Leverage Ratio. This definition is reworked on several places.

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June 24 2016

Comments on the Basel Committee on Banking Supervision Consultative Document on Reducing variation...

On 24 March 2016, the Basel Committee on Banking Supervision (BCBS) published a consultative document on constraints on the use of internal model approaches.

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April 10 2013

Comments by the German Banking Industry Committee on the Exposure Draft "Classification and...

With this Exposure Draft, the IASB has picked up on various points of criticism regarding the already finalised IFRS 9 (2009/2010). The key change is the proposed introduction of the FVTOCI category. The IASB has stated that such a category would...

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